Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Revision u/s 263 - the head of assessee’s income derived from its holiday homes i.e. whether it is income from house property as per the PCIT, business income going by the AO in assessment and the CIT(A) and the residuary had of “other” sources in its computation; respectively, is purely a debatable issue. - Assumption of jurisdiction u/s 263 is not proper.
Revision u/s 263 - the head of assessee’s income derived from its holiday homes i.e. whether it is income from house property as per the PCIT, business income going by the AO in assessment and the CIT(A) and the residuary had of “other” sources in its computation; respectively, is purely a debatable issue. - Assumption of jurisdiction u/s 263 is not proper.
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